Greencastle of North Aurora Inc C/O Embrace Living Communities

“Prior to its submission, form 990 is reviewed and approved by the finance department. It is then presented to the president and the board of directors for their review and approval”

“The corporation has a written conflict of interest policy. To ensure compliance with this , the corporation requires the following: on an annual basis, all members of the board of directors, the ceo, members of senior management, and employees with purchasing and/or hiring responsibilities or authority shall inform, in writing, the ceo and the chair of the finance/audit committee, of all reportable conflicts. Prior to the preparation of the disclosure statements, the finance department shall distribute a list of all vendors with whom the organization has transacted business at any time during the preceding year, along with a copy of the disclosure statement. The ceo shall review all forms completed by employees, and the finance/audit committee shall review all forms completed by directors and the ceo, and determine appropriate resolution in accordance with the next section of this policy. If a conflict arises during the year, the employee or board member will immediately notify the ceo who will determine appropriate resolution. All real or apparent conflicts of interest shall be disclosed to the finance/audit committee and the ceo of the organization. Conflicts shall be resolved as follows: the finance/audit committee shall be responsible for making all decisions concerning resolutions of conflicts involving directors, the ceo and other members of senior management. The chair of the committee shall be responsible for making all decisions concerning resolutions of conflicts involving finance/audit committee members. The chair of the board shall be responsible for making all decisions concerning resolutions of the conflicts involving the chair of the finance/audit committee. The ceo shall be responsible for making all decisions concerning resolutions of conflicts involving employees below the senior management level, subject to the approval of the finance/audit committee. An employee or director may appeal the decision that a conflict, or apperance of conflict, exists as follows: *an appeal must be directed to the chair of the board. *appeals must be made within 30 days of the initial determination. *resolution of the appeal shall be made by vote of the full board of directors. *board members who are the subject of the appeal, or who have a conflict of interst with respect to the subject of the appeal, shall abstain from participating in, discussing, or voting on the resolution, unless their discussion is requested by the remaining members of the board. Failure to comply with the standards contained in this policy will result in disciplinary action that may include termination, referral for criminal prosectuion, and reimbursment to the organization or to the government for any loss or damage resulting from the violation. As with all matters involving disciplinary action, principles of fairness will apply. Any employee charged with a violation of this policy will be afforded an opportunity to explain his/her actions before disciplinary action is taken.”

“All employees are co-employed by a peo (professional employment organization), group management services, inc. And embrace living communities. All forms, including w-2's and reports, are issued under the ein of group management services, inc. 34-1707723. The reporting organization reimburses embrace living communities for all employee compensation expenses.”

“The governing documents and the financial statements of the organization are available to the public upon request. The governing documents and the financial statements of the organization also can be found on the internet in websites for not-for-profit organizations like www.guidestar.com.”

“All employees are co-employed by a peo (professional employment organization), group management services, inc. And embrace living communities. All forms, including w-2's and reports, are issued under the ein of group management services, inc. 34-1707723. The reporting organization reimburses embrace living communities for all employee compensation expenses.”

“Embrace living communities, a not-for-profit corporation, is the managing agent and receives management fees as a percentage of the gross rents, including rental subsidies and other income under terms of a management agreement approved by hud. The managing agent is responsible for the day to day activities of the organization such as maintaining the building, resident support, hiring and supervising the employees. It also provides all the necessary bookkeeping and accounting services and submits all the required financial reports. All decisions and reports are presented and discussed with the board of directors and approved by the board of directors.”